Ukraine General License Number 17 - Authorizing the Wind Down of Transactions Involving the So-called Donetsk People’s Republic or Luhansk People’s Republic Regions of Ukraine (February 21, 2022)

Date issued: Feb. 21 2022

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TURBOFAC Commentary (415 words)

Notes:

1) This is a fairly ordinary "wind down" GL (compare Crimea equivalent at Ukraine General License Number 5). It presumptively authorizes the processing of underlying transactions that may not involve U.S. persons (see e.g., FAQ 807), but does not include authorizations for the "maintenance" of activities.

2) Refer to the Research System for documents dealing with the scope of the types of transactions that qualify for "wind down" GLs such as this. See in particular Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.

3) A notable difference vis-a-vis the Crimea wind-down GL is the Crimea GL had a proviso stating that the "general license does not authorize (1) any new exportation, reexportation, sale, or supply of...